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Federal R eserve b a n k O F DALLAS WILLIAM H. WALLACE F IR S T V IC E P R E S ID E N T October 17 , 1986 d a lla s , te x a s 75222 C ir c u la r 86-87 TO: The Chief Executive O fficer of a l l depository i n s t i t u t i o n s in the Eleventh Federal Reserve D i s t r i c t SUBJECT Request for public comment on a proposal for recovery o f automated clearing house f l o a t DETAILS The Board of Governors of the Federal Reserve System is re questing public comment on a proposal to recover the c o s t to the Federal Reserve of automated c l e a r i n g house f l o a t using a f l o a t f a c t o r p r ic in g methodology. The Board proposes to asse ss a f l o a t f a c t o r based on the d o l l a r value of ACHd ebit t r a n s a c t i o n s processed a t n ig h t. This f l o a t f a c t o r would be equal to the r a t i o of the p rojected c o s t of net d e b i t f l o a t to the projected value of ACH d e b i t t r a n s a c t i o n s processed a t n ig h t . The f l o a t f a c t o r would rep lace most of the c u r r e n t $.06 per item surcharge applied to ACH d e b i t items processed a t n i g h t . Because the c u r r e n t nig ht cycle surcharge recovers both f l o a t c o s t and higher operati ng expenses, the Board has proposed to a d j u s t the surcharge to recover only the higher co st of nighttime op e r a tio n s. The proposal would e s t a b l i s h a uniform nigh t cycle surcharge estimated a t $.015 fo r both d e b i t and c r e d i t ACH t r a n s a c t i o n s . ATTACHMENTS The Board's press r e l e a s e and document req uesting public comment are attach ed . MORE INFORMATION For f u r t h e r information, please co n tact Jonnie K. M i l l e r , Manager, E le ctron ic Payments Division a t (214) 651-6290, or Larry C. Ripley, A s s i s ta n t Vice P r e s i d e n t , a t (214) 651-6118. S incerely yours, For additional copies of any circular please contact the Public Affairs Department at (214) 651-6289. Banks and others are encouraged to use the following incoming WATS numbers in contacting this Bank (800) 442-7140 (intrastate) and (800) 527-9200 (interstate). This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org) FEDERALRESERVEpressrelease For Immediate release September 17, 1986 The Federal Reserve Board today Issued for public comment a proposal t o modify the method of recovering the cost of automated clearing house (ACH) f l o a t and to e s ta b lis h a nlg h t-cycle surcharge t o compensate for the higher operating co sts during t h i s time. Comment is requested by November 21. Federal Reserve f lo a t Is generated 1f there are delays 1n the System's handling of debit and cred it transactions. Debit f l o a t occurs when the System cred its the originator of a debit transaction before the receiver 1s charged. Credit f l o a t r e s u lts when the System receives funds from the originator of a credit transaction before the r e c e iv e r's account i s credited. To recover ACH f l o a t , the Board proposes to assess a flo a t factor based on the d ollar value of ACH debit transactions processed at night because the majority of ACH f l o a t occurs during t h i s time when large-d ollar debit transactions, primarily intra-corporate cash consolidations, are processed. This flo a t factor would be equal to the ratio of the projected cost of net debit f lo a t to the projected value of ACH debit transactions processed at night. The factor would then be applied to the value of a l l debit transactions deposited by an originating in s t it u t i o n at night to determine the fee for f lo a t to be assessed to that I n s tit u tio n . Because the current nlght-cycle surcharge recovers f lo a t costs and higher operating expenses, the Board has proposed to adjust the surcharge to recover only the higher co sts of nighttime operations. The proposal would estab lish a uniform n lg h t-cycle surcharge, estimated at $.015, for both debit and credit ACH transactions. The Board's notice i s attached. - 0- FEDERAL RESERVE SYSTEM (Docket No* R-0579) AUTO MAT ED CLEARING HOUSE FLOAT RECOVERY AGENCY: Board of Governors of the Federal Reserve System. ACTION: Proposed rule? request for comment, SUMMARY: The Board of Governors of the Federal ("Board") is recovering house requesting the ("ACH") cost of comments on a Reserve System proposed float generated method by automated of clearing transactions processed during the night cycle and a corresponding reduction of the current per item surcharge assessed on night cycle ACH transactions. Specifically, the Board proposes to establish each year a "float factor" equal to the ratio of the projected of float to the projected processed at night. value of all debit This to that of ACH factor would transactions institution at night assessed value The transactions then be applied deposited to determine institution. debit by the charge cost an for float factor to the originating float to be charges would be included in the institution's regular billing invoice. Because float, the float and night the this float cycle higher factor would recover surcharge, costs of currently operating at set the costs of to night, reduced to cover only the higher operating costs. recover could be Accordingly, the Board proposes to set the nighttime surcharge to cover only these higher operating costs, currently estimated at $.015 each for both debit and credit transactions. - 2DATE: Comments on the proposal should be submitted no later than .November 21, 1986. ADDRESS: data, Interested parties are invited to the Federal Reserve System, and Constitution Avenue, N, W . , Washington, deliver such comments to the guard Building Courtyard on 20th Street, Avenue and C Street, Docket No. R-0579. between provided in N. W.) 8:45 a.m. and section 261.6(a) (202/452-3879), (202/452-3955), station N. W. or Julius Division of Federal Attorney, 5:15 of Telecommunications p.m. Device the of the Federal the or (12 C.F.R. Earl Florence F. Division for Reserve as Regarding G. Hamilton, Young, Manager, Assistant Advisor (202/452-3878), Elaine Boutilier, (202/452-2418); the in Room except Rules to § 261.6(a)). M. Oreska, to Eccles inspected Board's Deaf Earnestine Hill or Dorothea Thompson Governors 20551, weekdays, Reserve Bank Operations; Legal in 20th Street (between Constitution Comments received may be FOR FURTHER INFORMATION CONTACT: Director, D. C. Secretary, Written comments should refer Availability of Information. Senior written views and other comments to William W. Wiles, Board of Governors of B-1122 submit ("TDD") or users, (202/452-3544), System, Board of Washington, D. C. 20551. SUPPLEMENTARY U.S.C. of 248a) Federal debit occurs and INFORMATION: Monetary Control Act (12 requires the Federal Reserve to recover the costs Reserve credit when The float generated ACH transactions processing delays are by priced may services. generate experienced. float, When Both which debit - 3transactions are processed, the receiver of be delayed funds flow to the originator the transactions. in processing, Should a debit from transaction debit float would be created because the originator's reserve or clearing account would be credited before the receiver's account would be charged. credit transactions, receiver. Should generated because transactions 1985, funds flow processing the before from delays originator the the originator occur, is receiver's In the case of credit charged account is to the float for is the credited. In the daily average ACH net debit float was $24.5 million, resulting in total float cost of $1.68 million. The processing majority of operations ACH float because transactions, primarily transactions, are most processed at processing delays night without a delay less time between during night. processing and the cash night debit consolidations Float is rarely because transactions the day in settlement. during large-dollar intra-corporate generated by the daytime operations up by occurs can be Also, settlement held processed there for at is generally transactions handled at night. Currently, the cost of net debit float attributable to processing delays is recovered through a surcharge applied to all debit transactions processed at night, which recovers the 1/ Total ACH float cost is determined by multiplying the daily average net debit float by the Fed Funds rate. - 4cost of the majority of ACH uniform surcharge creates processing inequities float. among users service because an institution originating debit transaction institution will pay originating transaction, yet the the a same large cost of 6^ (e.g. float on dollar transactions are of this the ACH a small (e.g. surcharge as $10,000) debit the larger transactions would be significantly higher. of small However, Thus, subsidizing $100) an dollar originators originators of large dollar transactions. In addition to current night surcharge the cross-subsidies caused for debit transactions, by the it appears that the level of the fee has been a disincentive for using the ACH to clear some point-of-sale address time-critical, and automated these concerns, and also reevaluated the small teller dollar payments, machine such transactions. Board considered the current surcharges as To two alternatives that are assessed to recover the higher costs of nighttime operations. Float Recovery — net debit float were Two alternatives for recovering ACH identified and evaluated. Under the first alternative, originators of debit transactions would be charged the cost of float (“charge-back") that would be generated when transactions they originated are delayed. similar to the procedures the Federal This method would be Reserve recover certain categories of check clearing second alternative, Banks float. use Under a "float factor" would be developed. to the The factor would equal the ratio of the projected cost of net debit float to the projected value of ACH debit transactions - 5processed 2/ at night.— The factor would then be applied to the value of all debit transactions deposited by an originating institution at night. Based on the cost of ACH debit float and the value of debit transactions processed at night during 1985, the float factor would have been $.0012 per thousand dollars of debit transactions million The debit originated. transaction, float charge would the be For an float originator charge in addition to would the of a be basic $3 $3.60. fee to process the transaction during the night cycle. Both the float factor and the charge-back alternatives have significant advantages over alternative reduces the and removes night. a Also, barrier each cause of some small-dollar alternative large-dollar surcharge. inequity associated with to processing the current would payments on these payments payments increase the ACH to migrate to the surcharge processed the cost and would the Each at of likely large-dollar wire transfer networks, thereby reducing payment system risk. The charge-back alternative current surcharge, customers benefit originating complex from the debit cost of the float. be because the the depository float, transactions, However, operationally, is more equitable than the that institutions is, would the whose institutions be charged for the the charge-back alternative would because float tracked at the individual payment level. would have to be The cost of 2J It is expected that the float factor would be set once a year, like other ACH fees, and would be based on budget information supplied by the Reserve Banks. - 6developing a mechanism to track level and the costs of float at the individual payment additional staff would method of float recovery cost effective. not make Therefore, this the Board is not proposing adoption of this alternative. The f l o a t factor equitable and simple to has the ad van tage implement. The that float it is b o th factor would be assessed on all night cycle transactions based on the value of 3/ transaction.— 7 each Currently, the institution's Reserve office collects transaction, so no additional originating depository information on each monitoring capability would ACH be needed. The Reserve Banks estimate that the cost of modifying existing software than $50,000 and to implement the float factor would be less would additional require no staff in the operations at the Reserve offices. A disadvantage of the float factor alternative is that the factor is consequently, cost. other set may to recover underrecover In this regard, however, estimated or float overrecover cost, actual the float factor and float is not unlike fees for payments services. Because depository the float institutions factor and does alternative not have is equitable the to operational complexity and high cost associated with the direct charge-back 3/ Although ACH debit float is primarily attributable to Tnterregional transactions, the Board is proposing to assess the float factor to all nighttime debit transactions to maintain the low administrative costs and operational simplicity of this alternative. - 7alternative, the Board is proposing to adopt this method for ACH float recovery. Nighttime Surcharges — recovery alternatives, surcharges were transactions the As part of the study of current reviewed. The is $.06, which nighttime present float processing surcharge for is intended to recover debit the cost of float and the higher operating costs of night processing. night surcharge for one-day credit transactions set to cover the additional operations. Currently, assessed night the operating two-day surcharge, cost credit in order is $.03 and of transactions are to earlier encourage At the time these implemented, assessing two-day credit nighttime believed transactions operations for that would these a use transactions. for other added transactions, delivery assessing a time small and many is for the that the is the same as institutions believe that the important, surcharge of Given costs of processing two-day credit transactions not fees were surcharge discourage is nighttime delivery of payroll transactions. it was The for it is two-day now believed credit that transactions should not affect significantly the use of this option. After proposes that transactions surcharge reviewing nighttime processing costs, the at night applied to processed at night. $.06 additional is based on should all cost be debit of recovered and processing through credit a the Board ACH uniform transactions The reduction in the debit surcharge from the assumption that float cost would be - 8recovered through transactions, the same. Therefore, be Based current on nighttime night float factor. In the case of credit the cost of processing one and two-day credits surcharge should the applied it proposed to both types information, surcharge for be approximately surcharge is would both it of is debit $.015. It provide for that a uniform credit credit is expected a more night transactions. estimated and is that the transactions that the equitable new fee structure, as the fees would reflect actual operating costs for all types of transactions processed. Therefore, the Board requests comments from interested members of the public on the proposed to recover "float factor" to be used the costs of ACH net debit float and the proposed adoption of a uniform surcharge for ACH transactions originated at night calculated to reflect the actual nighttime operating costs. Board of Governors of the Federal Reserve System, September 17, 1986. (signed) William W. Wiles William W. Wiles Secretary FEDERAL RESERVE BANK OF DALLAS STATION K DALLAS, TEXAS 7 5 2 2 2 RETURN POSTAGE GUARANTEED BULK RATE U.S. POSTAGE PAID DALLAS, TEXAS Permit No. 151